Fourteen front-running records, and seven are front running

Of 14 records this library tags front running, 7 hold up against their primary document: five were tagged from a boilerplate mention of the word, one is a different case, one records a conviction as a dismissal. The 7 genuine cases split into employees trading ahead of their own employer's book (5, gains $217,000 to $47 million) and brokers trading ahead of a customer's block order (2).

Published 2026-09-29 · 8 min read

Search this library for front running and it returns 14 case records. Read what each one’s primary document actually says, and seven of them describe something else.

Five were tagged from a single word appearing in boilerplate the regulator did not apply to the respondent. The Securities and Exchange Commission’s cease-and-desist orders against Deutsche Bank Securities Inc. and Mizuho Securities USA are both about equity research analysts leaking unpublished views to favoured clients — a real technique this library already tracks as newsletter scalping — and both orders cite the same 1988 congressional record noting that Section 15(g) of the Exchange Act “was intended to include a broad range of market abuses, such as insider trading, scalping, and front running.” That sentence is legislative history explaining what the statute covers in general. Neither order alleges that Deutsche Bank or Mizuho front ran anyone. The Deutsche Bank record also carries the wrong penalty: its case page states $100,000, which is the individual penalty a separate order imposed on the analyst Charles Grom in an unrelated proceeding cited in a footnote. The order actually before DBSI imposed a $9.5 million penalty on the firm.

The pattern repeats outside the SEC. ASIC’s 2017 infringement notices against UBS Securities concern incorrect disclosures about a crossing system and about trading as principal — UBS paid AUD $280,000 to close out two infringement notices, which under the regime is explicitly not an admission of a contravention. The release mentions front running exactly once, describing what the disclosure requirement is for: warning clients about “the risk of ‘front running’ by the participant.” That is a description of the harm a disclosure rule prevents, not a finding that UBS front ran a client.

One record has the wrong case attached. The SEC’s litigation release against Sean Wygovsky and Christopher Matthaei charges insider trading in advance of SPAC merger announcements — Wygovsky allegedly tipped Matthaei to nonpublic deal information, not to his employer’s pending orders. The release does mention front running, once, in a single sentence: “The SEC previously charged Wygovsky with perpetrating a lucrative front running scheme, and Wygovsky consented to a bifurcated settlement in that matter as well.” That prior matter is a different SEC action against Wygovsky alone, and it is not in this library. The record this library holds is the wrong one to carry the tag.

And one record has the outcome backwards. The Sergei Polevikov record is marked dismissed. Reading the SEC’s litigation release shows a final judgment entered against Polevikov himself on July 29, 2022 — enjoining him from further violations and holding him liable for disgorgement — and a parallel criminal conviction: Polevikov pleaded guilty and was sentenced to 33 months in prison. What the court dismissed, the same day and with the SEC’s consent, was a separate claim against a relief defendant, Polevikov’s wife, who had been named only for the purpose of recovering trading proceeds routed through her account. A dismissal of a relief defendant is not a dismissal of the case. This library’s own priority for corrections puts an inaccurate defendant outcome first for a reason, and this is that error, in the other direction: a conviction recorded as though the defendant had walked.

The seven that hold up

Strip out the five boilerplate matches and the one misattached case, and seven records remain, each independently confirmed against the regulator’s own order or complaint. They split cleanly into two kinds of relationship.

Trading ahead of your own employer’s book. Arya Motazedi, a gas and crude oil futures trader, placed orders for two personal accounts ahead of the orders he placed for his employer’s account on at least 12 occasions between September and November 2013, using his knowledge of his employer’s own pending trades. Christopher Gibson, who advised a private fund, sold a large block of shares for the fund and then, on the strength of knowing that sale was coming, traded ahead of it for himself, his father and his girlfriend — first in the underlying stock and later in put contracts he did not offer the fund the chance to buy. At Monness, Crespi, Hardt & Co., the firm’s research department maintained a formal “CIBRS Front Running report” specifically to catch employees trading ahead of the firm’s own unpublished research reports; the SEC’s 2014 order found the firm had the report and the policy but failed to enforce either, for a $150,000 penalty. And in the two most recent cases, Lawrence Billimek, an employee at a large asset manager, is alleged to have told an outside associate, Alan Williams, about his employer’s pending market-moving trades so that Williams could buy or sell ahead of them and split the resulting profit — an alleged $47 million over more than six years, still an allegation with a parallel criminal case pending. Sergei Polevikov, a quantitative analyst at two asset managers, did the same thing for himself: on nearly 3,000 occasions between 2014 and 2019 he bought or sold a stock on the same side of the market as his employer, ahead of his employer’s own trade in the same stock, closing the position the same day to capture the price move his employer’s own order was about to cause.

Trading ahead of a customer’s block order. The other two cases are brokers, not employees, and the person they front ran was a client rather than an employer. The CFTC’s 2018 complaint (this library’s case record still carries the placeholder title “Block Trade Broker”) names Andrew Gizienski, an associated person of the introducing broker EOX Holdings, who allegedly traded a friend’s discretionary account using confidential information about other EOX customers’ pending block trades in energy futures on ICE Futures US — that matter is still an unresolved allegation. The 2019 order (also carrying a placeholder title, “Energy Broker and Its Owner”) is Classic Energy LLC and its owner Mathew Webb, who on at least 63 occasions took the other side of customers’ block trades in natural gas futures into his own proprietary account — while still charging them a brokerage commission for the trade, as though he had merely arranged it with someone else. Webb’s order records a $1.5 million penalty and $413,065 in disgorgement.

The four cases with a comparable trading-gain figure in their primary document span two orders of magnitude: Motazedi’s twelve trades cost his employer about $217,000; Webb’s 63 trades on customer block orders put over $400,000 in his own account; Polevikov’s roughly 3,000 trades over five years totalled $8.5 million; and the SEC’s unproven allegation against Williams, run through an outside account rather than the employee’s own, is $47 million. Reading the four together suggests scale tracks repetition and duration more than any single technique variant — Motazedi and Webb are both one person trading ahead of order flow they could see, over months; Polevikov and the Billimek/Williams allegation both describe a scheme sustained for years.

How they were caught

The oldest and newest cases here point at a real shift in detection. Monness and Gibson, from 2014 and 2016, were both found through the ordinary mechanism of an SEC examination — reviewing a firm’s or an adviser’s own records and finding either a report nobody escalated (Monness) or a fund manager’s personal trades sitting next to the fund’s own block sales (Gibson). Motazedi was caught through the exchange’s own market surveillance, which the CFTC credits by name in its release, thanking CME Group’s Market Regulation Department. Webb’s case reads as though it traces back to customers noticing they were consistently on the wrong side of a trade Webb had “arranged.”

The two 2022 cases were both built by the SEC’s Market Abuse Unit using the Consolidated Audit Trail — the database that records, across US equity markets, which firm placed which order and exactly when. Polevikov’s release describes the analysis directly: the Division found nearly 3,000 same-side trades that consistently preceded his employers’ own trades in the same stock. The Billimek release says the same thing about Williams’s trading against his employer’s flow. CAT went live for equities in stages beginning in 2020, and both of the front-running cases this library holds that used it are from 2022 — too small a sample to call a trend, but consistent with what CAT was built to find: a pattern spread across years and thousands of trades that no single suspicious trade would surface on its own.

What this means for the library

None of this changes what front running is — the technique page describes the conduct accurately, and nothing in these seven confirmed cases contradicts it. It changes how much of the library’s own tagging under this technique should be trusted at a glance. Five records were tagged because a regulator’s order used the word “front running” while explaining what a different rule is for, and the two entity-level cases involving Ontario’s Capital Markets Tribunal — settlements with Royal Bank of Canada and with Toronto-Dominion Bank — read the same way: both statements of allegations list front running among eight or nine types of conduct that FX trading desk supervision is meant to prevent, in a matter that resolved as a supervisory failure rather than a specific finding of front running by either bank, and this piece treats them as unresolved on that narrower point rather than folding them into either count above. A technique tag assigned by keyword match will always need this kind of check against the primary document before a number gets quoted from it, which is exactly what this site’s own editorial policy says a reader should expect it to require.

Techniques referenced

• Front running — Front running is trading ahead of a customer order to capture the price improvement that order will produce, which breaches a duty owed to that customer rather than falsifying any public price.

Cases referenced

Reviewed September 29, 2026. Spotted an error? Tell us.